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xRM Safe Harbor Privacy Policy

We at xRM respect individual privacy and value the confidence of our customers, employees, consumers, business partners, and others. We collect, use, and disclose personal information in a manner consistent with the laws of the countries in which we do business, and we pride ourselves on upholding the highest ethical standards in our business practices.

This Safe Harbor Privacy Policy (the "Policy") sets forth the privacy principles that xRM follows with respect to personal information transferred from the European Union (EU) to the United States.

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. Companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Consistent with its commitment to protect personal privacy, xRM adheres to the Safe Harbor Privacy Principles.

This Safe Harbor Privacy Policy (the "Policy") applies to all personal information received by xRM in the United States from the European Economic Area in any format including electronic, paper, or verbal.

Definitions

For purposes of this Policy, the following definitions shall apply:

"xRM" is a California based company in the USA.

"Personal information" means any information or set of information that identifies or is used by or on behalf of xRM to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

"Sensitive" means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns an individual's health. In addition, xRM will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

xRM continuously educates its employees about compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance. xRM participates in the EU Safe Harbor Privacy Framework as set forth by the United States Department of Commerce.

Security: xRM will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement: xRM will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that xRM determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

Dispute Resolution: xRM has established internal management practices and policies to support the safe harbor principles. xRM encourages individuals with concerns about its information management practices to contact xRM at the address below. xRM has also agreed to participate in dispute resolution programs provided by the American Arbitration Association.

Limitation on Scope Principles: xRM will take all reasonable steps to comply with Safe Harbor Privacy Principles and this policy. Strict compliances with Safe Harbor Privacy Principles or these policies may be limited in certain cases and as required to meet legal, government or national security obligations. Information about limitations is set forth in the U.S. Department of Commerce Safe harbor website.

Contact Information: Questions about this Safe Harbor statement or how it is implemented by xRM may be directed to the following address: